Qantas Constitution

The Qantas Constitution (PDF) is Qantas' key governance document. The Qantas Sale Act requires the Constitution to contain specific provisions designed to reflect Qantas' position as Australia’s national carrier.

Driving ethical business practice

The Qantas Group is committed to complying with all applicable laws and regulations, and to conducting business with the highest standards of ethics and integrity.

We monitor global developments in governance, laws and business practices, and work collaboratively across our global footprint to ensure we continue to meet these standards. The Qantas Group Business Practices Document (PDF) provides an overview of our beliefs, values and business practices and highlights the standards to be upheld by all employees.

Risk management

Operating in an industry with unpredictable internal and external risks is part of the Qantas Group's everyday operating environment, whether it's in the price we pay for fuel, business and consumer confidence levels, weather patterns across our global network, or broader geopolitical events. We are committed to managing the risks by strengthening business resilience and building an agile, adaptive culture - giving us the foundations for sustainable performance in all market conditions.

Our approach to risk management starts with our first priority: the safety of our customers and people. Qantas was one of the first airlines to introduce an integrated Safety Management System in the 1990s, and we continue to evolve it. Today we apply the same systematic approach to all risk disciplines, not just aviation safety. We integrate aviation operational safety, work health and safety, aviation and cyber security, environment (including climate change) and business resilience, learning from collaboration and shared experiences to make the system better.

Qantas maintains a strong governance structure for threats and opportunities. The Board has overall responsibility for the governance of risks. Oversight is maintained through the Audit Committee and the Committee for Health, Environment, Safety and Security (CHESS).

The CHESS committee has responsibility for strategy, policy, systems oversight, monitoring and corporate governance over operational risks of the Qantas Group. This includes safety, WHS, environment, security (including cyber security) and business resilience matters. CHESS also has oversight of risks associated with regulatory compliance.

The Audit Committee undertakes the functions of a risk committee as set out in the ASX Principles. Risks are assessed under the Qantas Group Risk Assessment Guide (QRAG). The Audit Committee, at least annually, reviews Qantas Management’s establishment and operation of an enterprise-wide risk management system. This process is designed to identify, assess, monitor and manage all business risks, including strategic, operational, financial, and compliance risk.

The frequency with which the Board is informed about issues depends on the significance of the specific risk. Qantas’ risk register captures threats and opportunities that have been assessed using the QRAG, with medium, high and extreme risks reported to Executive Management. The Board of Directors and Executive Management receive a bi-annual Group Risk Report incorporating the Group Short Term (0-3 year) and Long Term (3-10 year) risk profile, trends, risk interconnectivity and monitors the progress of managing risks rated medium, high and extreme.

In addition, the Qantas Group has established a Sustainability Council to be the focal point for the Group’s understanding and integration of the forces that will shape the company, and to measure and communicate the long-term value drivers of the Group to key stakeholders, including our customers, people and shareholders.

The Council is made up of diverse senior representatives from across operational, commercial and corporate functions. The Council’s work feeds into key decision making forums across the Group, including the Group Management Committee and (via CHESS) the Qantas Board.

Supply chain assurance

Qantas takes a proactive approach to managing risks in our supply chain. We are working to make sure all 10,000 of our suppliers (or the partners we work with) prioritise safety and sustainability in the same way we do.

This program helps us understand how our suppliers are producing the goods and services we pay them for, and to make sure they comply with Qantas' Supplier Requirements.

We are mapping our supplier industries and locations to help us assess the relative risk. If we identify material risks, we will work with suppliers to remove the risks where possible, and otherwise to substantially mitigate them.

Anti-bribery and corruption

We recognise that corruption has a negative social, economic, political and anti-competitive impact wherever it occurs. We have a responsibility not only to meet expanding foreign and domestic anti-bribery legislation, but also to ensure that our business partners and those in our supply chain operate with a consummate level of integrity.

Our Code of Conduct and Ethics and our Group Business Practices document outlines the obligations of our employees, contractors and those we do business with in relation to anti-bribery and corruption, and together with guidance from global regulators, collectively form our anti-bribery and corruption compliance program.

Read more here:

The Group’s Business Integrity & Compliance function, reporting to the General Counsel and Group Executive, Office of the CEO, ensures that the Group is best positioned to respond to both the rapidly evolving regulatory environment and shifting societal expectations regarding corporate ethics. Our Business Integrity Compliance program is overseen by the Qantas Board, through the Qantas Audit Committee.

Supporting our Code of Conduct and Ethics is a suite of policy documents, procedures and guidelines that outline the minimum standards required of all our employees and support our employees to act legally and with integrity. With a focus on continuous improvement, the Group is seeking to build on our established compliance program by investing in technological platforms that will support our management of business risks and meet the growing expectations of our global regulators.

Our anti-bribery and corruption risk assessment program is being progressively launched across our global business. The output of this activity allows us to build a global risk profile to ensure that we focus our attention and resources on the highest areas of risk. Our sophisticated risk assessment utilises known bribery and corruption risk indicators and incorporates the Group’s established risk assessment procedures to identify potential risk and, where required, to introduce adequate controls to mitigate that risk.

Our Group training matrix identifies those employees who, due to the nature of their role, are required to complete anti-bribery and competition law training. We adopt a risk-based method to identify whether training is delivered face to face or online, which includes considerations of factors such as the corruption risk index of the country, the level of interaction with government, the nature of the business activity and the role of the employee. Using this risk-based approach, we also deliver training to contractors, agents or persons who may act on our behalf.

We support an ethical supply chain through our due diligence program, which assesses potential third-party suppliers, including those who act on our behalf, to identify those presenting an elevated risk of bribery. When assessing new business opportunities and ventures, our due diligence program assists us to assess and ensure that those we partner with operate with a commensurate level of integrity, operate within the law and meet our requirements.

The global nature of our business means that we have legitimate reason to interact with government and their agencies across the regions and countries in which we operate. As governments are key decision makers of issues that directly impact our business, we invest in building effective and collaborative relationships in order to achieve optimal business outcomes for the Group.

We are proud of our joint collaboration with government and broader industry to strengthen Australia’s approach to anti-corruption through our participation in dedicated focus groups, including our continued membership of the Business Integrity Council, and our association with industry bodies such as Verisk Maplecroft and Global Compact Network.

Whistleblower program

The Qantas Group highly values and promotes a speaking up culture, where all Disclosing Persons feel comfortable to raise matters that are of legitimate concern to them, including in relation to a potential breach of any legal or regulatory requirement or a Qantas Group Policy.

A Whistleblower program is an important element in deterring corrupt, illegal or other undesirable conduct. The Whistleblower Policy [PDF] outlines the operation of the Qantas Whistleblower program including what qualifies as a Disclosable Matter, how Qualifying Disclosures can be made (including the various channels available for disclosure), who qualifies as a Disclosing Person and who the Eligible Recipients for Qualifying Disclosures are. Further information regarding the investigation process and the protections available to Disclosing Persons is also available in the Policy.

In 2018, in line with the UNGPs, we invested in an independent salient human rights issues assessment, which identified the five most salient human rights issues for the Group. The assessment was not intended as a deep dive into any particular issue, but instead to help us to understand the issues where we could have the most severe impact on human rights through our own operations and business relationships. The assessment informed the integration of additional human rights considerations in our supply chain, including the development of a modern slavery risk index.

This risk index, tailored to the Qantas Group operating environment, is constructed with reference to the UN ‘Protect, Respect and Remedy’ framework underpinning the UNGPs, and assists us to embed responsible business practices, including throughout our supply chain, in line with international guidelines.

Read more here:

The Business Integrity & Compliance team advise and support the business on meeting the requirements of human rights related legislation, practices and standards, including through assessment of suppliers in our supply chain assurance program. The Supply Chain Steering Committee monitors the performance of the supply chain assurance program, and Qantas Group Audit & Risk providing oversight.

Since operationalising our Supply Chain Assurance program we’ve continued to assess how we interpret and respond to risk. We have matured our supply chain assurance program to introduce a modern slavery risk index and to improve due diligence, risk assessment and mitigation processes to address adverse human rights impacts where identified. Further detail on our supply chain assurance program can be found in our Modern Slavery Statement.

Our Modern Slavery Statement, pursuant to the Modern Slavery Act 2015 (UK) and aligning with the newly introduced Modern Slavery Act 2018 (Cth), is reviewed and published annually. It expresses our commitment and responsibility to identify and mitigate modern slavery and human trafficking within our organisation and across our supply chain. If we identify that we have caused or contributed to harm, in line with our commitments under the UNGPs, we will support remediation. We will also seek to mitigate adverse human rights impacts we might be directly linked to through our supply chain.

We are cognisant of the labour rights of our employees and persons operating in our supply chain. Qantas has expanded its supplier risk assessment to include a modern slavery risk index, incorporating the UN ‘Protect Respect and Remedy’ framework, that allows us to screen our operations and supply chain for labour rights violation risks and understand the areas that pose an elevated level of risk. We have developed specific risk indicators relating to underpayment, which enables us to carry out additional due diligence, remediation and monitoring activities.

In demonstration of our commitment to evolving our approach to human rights, we have focussed on broadening our stakeholder engagement with investors, shareholders and civil society to better understand their perspectives on the role of the aviation industry in respecting human rights.

As part of our wide-ranging contract with the Australian Government, we have commenced and maintain an open dialogue on a number of issues that directly impact our business, including in relation to human rights. Included in that dialogue has been the Group’s role in the repatriation of deportees who have not been granted asylum by the Australian Government: Read more below.

As a sponsor of the 2019 Global Compact Network Australia Conference, we held focus sessions with Professor John Ruggie, who was instrumental in establishing the UN Global Compact and is the author of the UNGPs, to assist us in continuing to evolve our broader human rights program and corporate responsibility strategy. Additionally, we have participated in a number of key events, including those run by the Global Compact Network Australia (member sessions) and attended forums to collaborate with industry, to consider emerging developments and enhance the business’s response to human rights issues.

Consistent with our commitment both to conducting business with the highest standard of ethics and integrity, and to aligning our business practices with our commitment to the UNGPs, Qantas recognises that airlines have a role to play in preventing human trafficking. The Group was a key sponsor of the International Air Transport Association’s June 2018 Annual General Meeting Resolution that denounced human trafficking and reaffirmed airlines' commitment to support governments and law enforcement to prevent human trafficking through awareness raising, staff training and reporting suspicious behaviour. We have commenced development of training for key personnel to detect and prevent human trafficking to be launched in early 2020, and we are working with relevant border agencies in identifying the appropriate response mechanisms.

The Group acknowledges the complexity of immigration issues and respects that there are various views in the community and amongst shareholders about Australia’s immigration policy.

As a part of our wide-ranging contract with the Australian Government, the Group repatriates’ deportees from Australia. While the overwhelming majority of transportations involve the return of unlawful non-citizens to New Zealand, the United Kingdom, the United States of America and Japan, on rare occasions the Group transports deportees who have sought and been denied asylum by the Australian Government.

The complexities attending the deportation of the unsuccessful asylum seekers and the multiple stakeholders involved, including intelligence, security and regulatory bodies, has meant that the Group must adopt a consultative and measured approach to identify appropriate response options. This includes thorough consideration of our commitment to align our policies and practices with the UNGPs.

The Group’s dialogue with multiple stakeholders, including civil society (for example the Australasian Centre for Corporate Responsibility and the Refugee Advice & Casework Services), investor groups and Professor John Ruggie, has informed the Group’s implementation of its commitments under the UNGPs, the UN Global Compact and other international standards. Professor Ruggie met with the Group Management Committee in May this year, with a focus on discussing what the UNGPs mean for the Group. This included discussing the Group’s position in relation to the carriage of involuntary deportees, a category that includes persons who overstay working visas, persons denied entry for visa irregularities, criminal extraditions and, on rare occasions, persons who have been unsuccessful in claiming asylum status in Australia.

The Group has considered transport of unsuccessful asylum seekers through multiple lenses, including as part of the salient human rights issues assessment undertaken in 2018; a targeted risk assessment inclusive of the impact to our broader stakeholder group; and the Group’s capacity and qualification to “second guess” a complex and comprehensive regulatory and judicial process.

Consistent with the Group’s consultative approach, we have been in ongoing dialogue with the Department of Home Affairs about the repatriation of deportees who have not been granted asylum by the Australian Government. Through this dialogue we are aware that the Department will be amending its Persons in Custody (PIC) Form, a document provided by the Department in conjunction with a request to remove a person from Australia, prior to any transport taking place. The amendment will inform airlines whether, prior to any international transportation, an individual has outstanding proceedings before a court or tribunal. This amendment provides the Group with an additional level of verification in line with our voluntary commitments under the UNGPs, while at the same time upholding our position that the Australian Government is best placed to make decisions on the legal status of people seeking asylum in Australia.

We aim to foster a workplace where people respect and tolerate the rights and differences of others. Harassment in the workplace is not tolerated and is a form of discrimination if it is based on an unlawful ground such as gender, race or disability. Likewise, bullying or any form of occupational violence in the workplace is not tolerated.

If any of our people feel that they are being harassed, bullied or discriminated against, they can contact their manager or Human Resources Representative.

Our inclusion and diversity strategy is focused on driving an improved people experience (and in turn, better business outcomes) by removing barriers to inclusion and creating greater opportunities for participation. We do this by mitigating unconscious bias and improving access to flexibility, talent programs and dedicated leadership development.